stewardship plan proposal · services will be available, free of charge, to disabled and homebound...

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COUNTY OF SANTA CLARACONSUMER AND ENVIRONMENTAL PROTECTION AGENCY

SAFE DRUG DISPOSALSTEWARDSHIP PLANPROPOSALMAY 23, 2020

1 © Inmar 2020 Inmar authorizes the posting of the plan dated May 23, 2020 in accordance with the California Public Records Act, as well as Section B11-543 of the County o f Santa Clara Ordinance Code for the purposes of making it available to the public for review and comment. Any other use requires express written consent of Inmar

Proposal Summary ............................................................................................................................................................ 02 I. Producer Participation in Plan | Contact Information ......................................................................................................... 02 II. Proposed Collection System ............................................................................................................................................. 03

A. Kiosk Service ........................................................................................................................................................ 03 B. Mail-Back Services ............................................................................................................................................... 10

III. Handling and Disposal ....................................................................................................................................................... 13 IV. Policies and Procedures .................................................................................................................................................... 14 V. Patient Privacy ................................................................................................................................................................... 17 VI. Outreach Program Design ................................................................................................................................................. 17 VII. Program Goals ................................................................................................................................................................... 22 VIII. Drug Separation & Recycling .......................................................................................................................................... 23 IX. Annual Reports .................................................................................................................................................................. 23

Appendix ................................................................................................................................................................................. 26

A. Potential Collection Sites ............................................................................................................................................. 27 B. Kiosk Signage ............................................................................................................................................................. 32 C. Training Material ......................................................................................................................................................... 34 D. Promotion Material ...................................................................................................................................................... 55 E. Applicable Permits and Licenses ................................................................................................................................ 62


PROPOSAL SUMMARY Inmar will provide a comprehensive Stewardship Plan compliant with Santa Clara County Ordinance number NS-517.91 and the Safe Drug Disposal Regulations and will include Covered Drug collection methods supported by outreach and education programs to increase County Resident awareness and participation. The Stewardship Plan will provide safe, secure, and convenient access on an ongoing basis for County Residents and will be funded by participating covered Producers. The program will also provide reporting on collection metrics and results of education and outreach campaigns. Inmar will notify the applicable governing bodies fifteen (15) days prior to making any changes to the program that materially impact the operation of the Stewardship Plan. All capitalized terms not otherwise defined shall have the same meaning as in the Ordinance and Regulation.

Inmar’s proposal includes the following:

• Equitable & Reasonably Convenient Access: Kiosk placements at authorized Collectorlocations and alternative methods for underserved areas (e.g., Mail-Back Service envelopesand Take-Back Events)

• Covered Drug Collection Systems:

o Kiosk Service: Turn-key program with DEA and DOT compliant processes andmaterials

o Mail-Back Services: Available for distribution at select authorized Collectors or byrequest via a website or toll-free phone service

o Take-Back Events: Coordinated initiatives with local authorities to manage secureevents at alternative locations in underserved communities

• Education & Outreach: Strategic deployment of Inmar’s Media assets and expertise as well asfar-reaching retail Pharmacy relationships, to drive awareness and participation

• Annual Reporting: Insight into required collection and outreach metrics.

I. PRODUCER PARTICIPATION IN PLAN | CONTACTINFORMATION Ordinance No. NS-517.91 § B11-542(a)

1. Inmar Plan Liaisons

Nick MassaroManagerConsumer Drug Take Back Solutions


635 Vine Street Winston Salem, NC 27101 Email: [email protected] Phone: 336-770-1992

2. Producer(s)

Unichem Pharmaceuticals, USASanjeev ParabDirector, Finance1 Tower Center Boulevard, Suite 2200East Brunswick, NJ 08816Email: [email protected]: 732-253-5954

Inmar has secured commitments from additional producers and upon Plan approval by the department, will provide a supplemental list with the Producer names and contact information.

II. PROPOSED COLLECTION SYSTEM Ordinance No. NS-517.91 § B11-542(b)

Kiosk placements at authorized Collector locations will be reasonably convenient and alternative methods for underserved areas (e.g., Mail-Back Services envelopes) will be available. Per § B11-545(a) “Stewardship Plans – Collection of Covered Drugs” Inmar does not require any Person to serve as a Collector in a Stewardship Plan. A Person may offer to serve as a Collector voluntarily or may agree to serve as a Collector in exchange for incentives or payments offered by a Producer, group of Producers, or Stewardship Organization. In accordance with § B11-545(b) (3) “Stewardship Plans – Collection of Covered Drugs”, Inmar will prioritize a collection system at Retail Pharmacies and law enforcement agencies as well as community collection events along with Mail-Back Services available at public buildings.

All drop-off sites shall accept all Covered Drugs from County Residents during all hours that the Collector is normally open for business to the public.

Inmar will utilize hospitals with on-site retail pharmacies and law enforcement agencies as necessary to meet the goals of equitable and reasonably convenient access for County Residents, as outlined in § B11-545(b)(1). However, it is our expectation that the majority of drop-off sites will be Retail Pharmacies.

A. KiosksPursuant to the Ordinance §B11-545(b) (2), Inmar complies with DEA regulation 21 CFR Parts 1317.60(c) and 1317.70(f), and seals all drop-box liners and Mail-Back envelopes. These liners and envelopes shall not be opened, x-rayed, analyzed, or otherwise penetrated. Accordingly,

mailto:[email protected]



their contents shall not be sorted or inventoried subsequent to being placed into a drop-box or mail-back envelope. Patient Privacy is addressed more specifically in Section V.

Pursuant to the Ordinance §B11-545(b)(3-4), Inmar will give preference to Retail Pharmacies and law enforcement agencies wherever possible to voluntarily serve as drop-off sites for Unwanted Covered Drugs. Inmar will work with all Collectors to validate that the requirements in §B11-545 including all relevant DEA and State of California Board of Pharmacy requirementsare met.

Kiosk Specifications and Design Inmar’s kiosk is made in the USA and produced from 16-gauge cold-rolled steel, and with an easy-to-use, Americans with Disabilities Act (ADA)-compliant drop-box design. County Residents can easily drop Unwanted Covered Drugs through the drop door and into the shippable container and inner liner inside. The container is a 275 lb-rated box with a 6-mil DEA-compliant liner. Liners are either 18 gallons or 35 gallons dependent upon geographical location and population density of the kiosk location. This volume rating is printed directly onto our 6-mil DEA-compliant liners and has passed the tests prescribed in accordance with ASTM D 1922 and ASTM D 1709.

There are several unique features that enhance the effectiveness and security of the Inmar kiosk. For example, the top of the kiosk is sloped, limiting the ability to stack items on top. In addition, the drop slot features an extended metal drop door that lowers into the container to detect when product capacity is reached. When the drop door encounters resistance within the kiosk, it is an indication that it is time to change the container. This manual capacity indicator eliminates the need to change batteries and/or sacrifice the location of the kiosk to be proximate to an electrical outlet. Lastly, the container access door is reversible to allow for convenient placement in any appropriate location in the Pharmacy.

Per DEA requirements, the kiosk must be installed in the line of sight of Pharmacy or DEA registrant employees and bolted to the floor or a permanent fixture. The Inmar kiosk has pre-drilled holes in the bottom for easier installation. It also features a 4-point locking system with steel projections in two center locations at the top and bottom of the door which are activated when locked for strengthened security. The top and bottom deadbolt locations are hidden from the outside to prevent break-ins.

The Inmar kiosk will have signage that communicates what is and is not allowed to be placed inside, as defined by §B11-540. Definitions. The signage will also feature a website and toll-free phone number (detailed further in Section IV) so users of the program can ask questions and locate additional program information.

Inmar’s DEA and ADA compliant kiosk is sent to the authorized Collector along with enough supplies for 3 returns. Supplies include:

• Preaddressed, prepaid serialized container• Serialized inner liners to protect against puncture and provide a liquid barrier


• Easy-to-use zip ties to seal inner liner compliantly• Absorbent pad for placement in the bottom of the inner liner bag

Kiosk design features

Kiosk Components


Pick-Up and Disposal Coordination Options For the safe on-site removal of contents and servicing of kiosks, Inmar abides by the DEA regulations in 21 CFR 1300 et al.

Inmar will work with each authorized Collector to develop a collection schedule that works specifically for their location - either an on-site or self-service option. Inmar will also be at the ready with service technicians should emergency service be required. For a pickup request outside of the normal schedule, the standard response time is 48 hours. Regardless of the service model chosen, Inmar, with its contracted disposal partners, will provide direct feedback using discrepancy reports to prompt any corrective action needed should liners reach disposal facilities in a non-compliant manner, i.e. taped incorrectly, overweight, etc. Feedback is communicated directly to pharmacy locations as well as any technicians who may have assisted or serviced a return as described below. Any discrepancies will be included as required in the annual reports.

Self-Service Returns As provided for by the CA Board of Pharmacies, Inmar will train authorized Collectors to service the containers on their own to allow for expedited servicing as desired. The steps to service a container are fast, efficient, and DEA-compliant. Inmar will provide authorized Collectors with training materials including step-by-step instructions for tracking, sealing, shipping, and replacing collection containers. Training materials are provided in Appendix A. The process for the pharmacy once a Kiosk is installed is as follows:

• Pharmacist receives the liner kit• Pharmacy team (consisting of 2 pharmacy employees) constructs the container with inner

liner, inserts and securely locks the kiosk• Pharmacy team unlocks the kiosk drop door to enable consumer use• Installation date of inner liner is documented and witnessed by on Tracking Sheet (Included

in Appendix A)• Once kiosk is full, pharmacy team members will jointly open kiosk• Container and inner liner is removed and documented on the Tracking Sheet.• Container is packaged (inner liner is zip tied, outer box is taped) to be compliant with all

DOT Hazardous Materials Regulationso The sealer inner liner will not be opened, x-rayed, analyzed, or otherwise penetrated.

• If the container (and inner liner) must be shipped at a later time (shipment cannot take placeat time of service), storage of the container behind pharmacy counter must be notated onthe Tracking Sheet

• Replacement container and inner liner is constructed, inserted, secured into kiosk anddocumented on the Tracking Sheet

• Pharmacy team contacts FedEx for pickup of container (and inner liner) for shipping toauthorized Disposal Facility for destruction

*At no point will the pharmacy have to store the filled container for longer than 48 hours after callingFedEx.


Technician-Assisted Returns Inmar will provide contracted employees (“technicians”) who will be trained specifically in servicing kiosks in a geographically-assigned area. These technicians will establish a pattern for servicing the Collectors utilizing service metrics to establish an appropriate pattern of service. The service will include the following:

• Pharmacist team receives the liner kit• Pharmacy team contacts preassigned technician staff to construct container with inner liner,

insert and securely lock kiosk with 2 pharmacy employee witnesses.• Technician unlocks the kiosk drop door to enable consumer use• Once the kiosk is full (or until routine schedule is established), pharmacy team contacts

preassigned Inmar technician for service• Upon arrival, technician will observe the condition of the kiosk• Technician will notify pharmacy team of arrival• Pharmacy team witnesses technician change out of kiosk supplies• Container and inner liner is removed and documented on the Tracking Sheet.• Container is packaged (inner liner is zip tied, outer box is taped) to be compliant with all

DOT Hazardous Materials Regulations• The sealer inner liner will not be opened, x-rayed, analyzed, or otherwise penetrated.• If the container (and inner liner) must be shipped at a later time (shipment cannot take place

at time of service), storage of the container behind pharmacy counter must be notated onthe Tracking Sheet.

• Replacement container and inner liner is constructed, inserted, secured into kiosk anddocumented on the Tracking Sheet

• Pharmacy team contacts FedEx for pickup of container (and inner liner) for shipping toauthorized Disposal Facility for destruction

• Technician will perform general clean-up and wipe-down of kiosk• Notation of container serial number removed, and serial number installed along with

signatures by 2 pharmacy employees (witnesses)• Sealed container (and inner liner) will be placed behind the pharmacy counter to await

FedEx pick up and documented accordingly on the Tracking Sheet*• Final signature from pharmacy personnel of completion of service event is obtained

*At no point will the Pharmacy have to store the filled container for longer than 48 hours after callingFedEx.

Full-Service Returns Inmar will offer on-site service for the collection, replacement, and shipping of full containers. This all-inclusive program removes the burden for the authorized Collector and the Pharmacy employees. Inmar will initiate standard service intervals for each Collector. Once a pattern of usage has been established, the service schedule will be adjusted with the agreement of the authorized Collector to provide the best overall service with minimal interruption. Inmar will work with the Collector to adjust the schedule based on utilization of the receptacle.


Inmar will provide two employees with all appropriate DEA and DOT function specific training to specifically service kiosks. Upon installation of the Kiosk, the process for Full-Service Events will include the following:

• Pharmacist receives the liner kit• Pharmacist contacts preassigned Full Service staff to construct container with inner liner,

insert and securely lock kiosk.• Full Service staff will unlock the kiosk drop door to enable consumer use• Once the kiosk is full (or until routine schedule is established), pharmacist contacts

preassigned Full Service Staff service• Upon arrival, Full Service staff will observe the condition of the kiosk• Full Service staff will notify pharmacist of arrival• Full Service staff will remove the container and inner liner and document on the Tracking

Sheet.• Container is packaged (inner liner is zip tied, outer box is taped) to be compliant with all

DOT Hazardous Materials Regulations• The sealer inner liner will not be opened, x-rayed, analyzed, or otherwise penetrated.• Replacement container and inner liner is constructed, inserted, secured into kiosk and

documented on the Tracking Sheet by the Full Service staff• Full Service Staff will perform general clean-up and wipe-down of kiosk• Full Service Staff will unlock the kiosk drop door to enable consumer use• Installation date of inner liner is documented and on Tracking Sheet (Included in Appendix

A)• The sealer inner liner will not be opened, x-rayed, analyzed, or otherwise penetrated• Full container (and inner liner) will to be taken directly to FedEx by Full Service Staff to be

sent directly to authorized Disposal Facility for destruction• Final signature from pharmacists upon completion of the Full-Service Event is obtained

Auto-Replenishment of Kiosk Supplies Regardless of service option selected, the supplies used to collect and transport Unwanted Covered Drugs are provided in automatically-replenished “kits” of three. Each kit includes: pre-labeled and pre-paid cardboard box containers, liquid barriers and serialized, puncture-resistant inner liners. The kit mailers, when packaged with the interior components, are approximately 6 inches thick. The mailer is cinched tightly around the inner components, which makes for a very easy-to-store kit. Kits can be stored behind the Pharmacy counter, behind a door, or under or behind a desk, with no ongoing maintenance required.

Upon receipt of the liner at our destruction partner’s site, an electronic raw data file via SSH File Transfer Protocol (SFTP) with the weight, serialized barcoded label information and tracking information is passed to Inmar. This information is then received and entered into our Order Management log and Inbound Receipts log. The system tracks when the second of the three inner liners is received at the destruction partner. Inmar then initiates a reorder trigger for the next kit to


be shipped. Auto replenishment reduces the amount of inventory maintained at the Collector while maintaining sufficient supplies to keep the kiosk continuously operable. Additional considerations will be made for locations expected to have high volume of returns for multiple initial kits to insure an adequate supply of liners.

Collector Site Locations Inmar has an extensive retail network consisting of major retail partners (e.g. Safeway, Walmart and Rite Aid) and will leverage those relationships to engage participation in this Stewardship Plan. Appendix A includes a list of proposed locations that would utilize a kiosk as the collection method upon becoming a Collector.

Inmar will reach out to these retail Pharmacies as potential Collector sites and will utilize hospitals with on-site pharmacies, and law enforcement agencies as necessary to ensure equitable and reasonably convenient access to County Residents.

Inmar will work to establish drop-off sites within three months of the Collector’s offer to participate unless the Collector requests a longer time frame.


B. Mail-Back Services Ordinance No. NS-517.91 § B11-545(b)(5)

Pursuant to the Ordinance §B11-545(b)(5) Inmar will provide prepaid and preaddressed mailers to County Residents containing written instructions for returning Unwanted Covered Drugs. Mail-Back Services will be available, free of charge, to disabled and homebound County Residents upon request through the Stewardship Plan’s toll-free telephone number and website, and through distribution of prepaid, preaddressed mailers at a minimum of five convenient Mail-Back Distribution Sites per County of Santa Clara Supervisorial District. This service will be available to all County Residents upon request.

i. Mail-Back Distribution SitesReturn envelopes will be distributed at approved Mail-Back Distribution Sites. County Residents willbe able to locate the Mail-Back Distribution Sites nearest to them on Inmar’s LifeInCheck™Consumer Covered Drug Take-Back program website, https://rxdisposal.lifeincheck.com/.

Inmar will establish Mail-Back Distribution Sites to supplement service in any area underserved bydrop-off sites pursuant to § B11-545(b)(5).

Inmar is committed to providing all Pharmacies an option to supply their customers with informationregarding Mail-Back Services. Inmar will provide Pharmacies, Doctor’s offices, community servicesoffices and law enforcement offices with small cards that can be handed out to County Residentsthat may need access to this service. The card will instruct them to either call or visit the website tolocate the nearest kiosk or request a mailer. Additionally, Inmar will reach out to Pharmacies fillingprescriptions by mail to include the cards for the same options. A sample card is provided below:

Sample Business Card – Request Mail-Back Envelope

https://rxdisposal.lifeincheck.com/


Inmar will also work with the Director, local law enforcement agencies, and local communities to determine the appropriate number Mail-Back Distribution Sites and their specific locations.

ii. Requesting Return Envelopes or Auto-Injector containersCounty Residents will be able to request mailers via Inmar’s LifeInCheck™ Consumer Covered DrugTake-Back program website (https://rxdisposal.lifeincheck.com/) or the Inmar LifeInCheck™Consumer Covered Drug Take-Back toll-free phone service.

Mailers will meet DEA requirements:• Preaddressed, postage paid• Nondescript, and do not indicate what may be inside• Waterproof, tamper-evident, tear-resistant, and sealable• Contain a unique ID number that allows for tracking• Include instructions for the user that indicate the process for mailing the package, substances

that can be sent, notice that packages can only be mailed in the US customs territory, andnotice that the only packages provided by the authorized Collector will be accepted

• No personally-identifiable information will be requiredMailers are white in color with a gray interior and 7” x 10”. The mailer includes a 3” perforated lip security seal. While only one size envelope is available at this time, should a County resident require more than one mailer, multiple mailers will be available via the program website, toll-free phone line or at Mail-Back Distribution Sites.

A sample envelope is shown on the next page

https://rxdisposal.lifeincheck.com/


Sample Envelope

Front Back

Mail-Back Tracking

All Mailers, regardless of type, distributed by authorized Mail-Back Distribution Sites will be tracked in a method similar to the kiosk collection containers. Mailers will have a unique, serialized identification number. Once the mailer arrives at the Disposal Facility, the serial number and weight will be noted before final disposition.

Mailers distributed directly to County Residents via the website or via toll-free phone number requests will be tracked by Inmar when sent to County Residents and tracked at the Disposal Facility when they are returned.

This tracking process will allow Inmar to report the number of mailers distributed and returned in the Annual Reporting provided to the Director, as required.


Take-Back Events Inmar will provide kiosks at regional locations convenient to the public and will conduct and promote Drug Take-Back Events in conjunction with a local law enforcement agency and in coordination with any National Consumer Drug Take-Back Day’s promoted by the DEA if requested by the Directors,

III. HANDLING AND DISPOSAL Ordinance No. NS-517.91 § B11-546

Pursuant to Ordinance §B11-546(a) Inmar complies with all local, state, and federal laws and regulations applicable to disposal of pharmaceutical waste and controlled substances.

Kiosk containers will be sent using Inmar’s DOT Special Permit #20499, from the authorized Collector via FedEx to Inmar’s third party contractor, 123 Compliance Logistics, LLC, a licensed DEA Reverse Distributor-Collector. All mailers will be sent via USPS to 123 Compliance Logistics. 123 Compliance Logistics will record the following information upon receipt of every individual container and mailer:

• Date received• Serialized barcode label information• Tracking information (Kiosk containers only)• Weight• Date transported to disposal facility• Disposal Date• Manifest number (if applicable)

All information recorded will be transferred back to Inmar on a daily basis as part of the electronic raw data file via SSH File Transfer Protocol (SFTP). Any discrepancies observed at 123 Compliance Logistics will be recorded on discrepancy reports to prompt any corrective action.

123 Compliance Logistics operates in full compliance with DEA § 1317.75(c) which prohibits handling substances after they have been deposited into a collection kiosk.

All product shipped directly to 123 Compliance Logistics will be transported using their contracted, licensed hazardous waste transporter, TransChem Environmental to the appropriate disposal facility to be incinerated quickly, securely, efficiently and in accordance with all DEA requirements. 123 Compliance Logistics will be responsible for all DEA Form 41 record keeping requirements. Please refer to the table below for the contracted disposal locations.

In reference to § B11-546(a)(b) “Stewardship Plans – Disposal of Unwanted Covered Drugs”, 123 Compliance Logistics, TransChem Environmental and FedEx will comply with all local, state and federal laws and regulations surrounding the transportation and disposal of Unwanted Covered Drugs. Contact information and registration information is listed in the table below.


Copies of all relevant permits can be found in Appendix E

Information on FedEx’s 5-year record of penalties, violations and/or regulatory orders received is detailed in its SEC filings found on http://investors.fedex.com/financial-information/sec-filings/default.aspx

IV. POLICIES AND PROCEDURES Ordinance No. NS-517.91 § B11-542(d) Ordinance No. NS-517.91 § B11-545(b2) Ordinance No. NS-517.91 § B11-546(b-c)

Inmar operates collection kiosks across 46 States and the District of Columbia as part of its operations today and maintains compliance with all federal and state rules and laws. Inmar will comply with all applicable laws, rules, and regulations as specified by the program requirements and require by contract where applicable that vendors and Collectors are also compliant with all laws, regulations, and legal requirements.

Inmar Collectors and vendors will specifically be required to comply with The Controlled Substances Act, 21 USC sections 801-971 and 21 CFR Part 1317; United States Department of Transportation Hazardous Materials Regulation, 49 CFR parts 100-185 and all applicable Santa Clara County Ordinances and Regulations.

The DEA allows law enforcement agencies, Retail Pharmacies, Reverse Distributors, hospitals or clinics with onsite Pharmacies, and certain other entities to be registered with DEA as an authorized Collector.

Company Name Contact Information

Registration Information Type of Incineration

123 Compliant Logistics, LLC 2626 N 29th Ave Phoenix, AZ 85009

Rory Buske 602-612-4140

DEA Reverse Distributor-Collector: R90571264

N/A

Clean Harbors Aragonite 11600N. Aptus Rd. Aragonite, UT94029

Michael Marlow 435-884-8100

EPA ID: UTD981552177

Hazardous Waste Incinerator

Clean Harbors El Dorado, LLC 309 Anerucan Circle El Dorado, AR 71730

Dan Roblee 870-863-7173

EPA ID: ARD069748192


Veolia ES Technical Solutions, L.L.C7665 Highway 73Port Aurthur, TX 77640

David Michaelis 281-216-9618

EPA ID: TXD000838896


TransChem Environmental 542 East 27th Street Tuscon, AZ 85713

520-829-5651 DOT Registration: 052119550060B Hazardous Materials Safety Permit: US-1341480-AZ-HMSP

Hazardous Waste Transporter

FedEx Eric Stillson 800-469-9993

Common Carrier

http://investors.fedex.com/financial-information/sec-filings/default.aspx

http://investors.fedex.com/financial-information/sec-filings/default.aspx


Inmar has established standard operating procedures that require Collectors to adhere to these standards. Any Collector agreements specifically require their compliance ensuring their commitment to compliant operation of the collection kiosk and shipping of contents in compliance with the DEA regulations. A refusal to sign the agreement or comply with the DEA regulations would be a reason why a Collector could be excluded from the Santa Clara County Stewardship Plan.

DOCUMENTATION AND TRACKING Collection containers and inner liners will have a unique, serialized identification number to enable tracking at all stages of the return process illustrated below.

Tracking is well documented as evidenced by the Inmar serialization tracking form which is referenced below. This form must be completed and witnessed by two authorized Collector employees, which assures compliance and safety across the program, and internally by both the Stewardship Organization and the Collector.

The purpose of this form is to document the use of the serialized inner liner throughout the collection process and to help the authorized Collector meet DEA and Board of Pharmacy record-keeping requirements. Inmar requires each authorized Collector to understand and comply with all federal, state, and local regulatory requirements pertaining to Unwanted Covered


Drugs applicable at the authorized Collector's registered location.

The serial numbers, date acquired, and signature of one authorized Pharmacy employee must be completed upon receipt of the container and inner liner. As illustrated above, the date installed is to be completed by two authorized Pharmacy employees with their names and signatures. The date the container and inner liner are removed from the kiosks is also to be noted with names and signatures. Finally, the date the container and inner liner are shipped is noted with authorized names and signatures.

Authorized Collectors must maintain a copy of the completed form, a copy of the FedEx tracking information, and other records as applicable, on file at the Collector for at least two years.

This tracking process will allow Inmar to report the number of collection-site-containers/inner liners distributed and returned in the Annual Reporting provided to Santa Clara County, as required.

Transport The Collector will properly seal, store securely, and arrange for pickup of the container from the registered location in a manner consistent with DEA regulations. The container will include a preaddressed and prepaid shipping label. The FedEx representative will take possession of the container and deliver it to Covanta for incineration.

Disposal Once the container arrives at the Disposal Facility, the serial number will be noted before final disposition, which allows Inmar to report the number of containers distributed and returned in the reporting provided to the County, as required.

Compliance with Applicable Laws Inmar operates across 46 states and the District of Columbia and maintains compliance with all applicable federal, state, and local laws. Inmar, its vendors and Collectors will comply with the program requirements.

Inmar’s training materials, found in Appendix C, aid the Collector in proper kiosk installation, which helps optimize the security of the unit. The training materials also include information on kiosk operation, inner container materials, assembly and placement, regulated shipping instructions, program FAQs, and serialization tracking.


V. PATIENT PRIVACY Ordinance No. NS-517.91 § B11-542(e) Ordinance No. NS-517.91 § B11-546(a)

Inmar provides significant training to our participating authorized Collectors and strictly follows the DEA guidelines for the proper handling of the kiosks and inner liners. This begins with the proper training of the authorized Collector in the compliant operation of the kiosks and proper preparation, removal, and packaging of the container. It also involves the training of the Inmar employees that may come into contact with the full container to ensure proper handling. Inmar is very strict in our compliance to the DEA guideline as cited below. According to the DEA - As provided in §§1317.60(c) and 1317.70(f), inner liners shall be sealed immediately upon removal from the permanent outer container; sealed inner liners and returned Mail-Back Services packages shall not be opened, x-rayed, analyzed, or otherwise penetrated. Accordingly, their contents shall not be sorted or inventoried subsequent to being placed into a collection receptacle or Mail-Back Services package. To clarify this, § 1317.75(c) was modified to add the prohibition against individually handling substances after they have been deposited into a collection receptacle.

Inmar has a long history of serving both commercial and government clients subject to stringent requirements. For example, Inmar’s Pharmacy applications manage Protected Healthcare Information (PHI) and are HIPAA compliant. Additionally, as part of Inmar’s Rx Returns (reverse distribution) business, we work very closely with regulators to implement compliant procedures covering the DEA, Board of Pharmacy, EPA, and other tangential regulatory entities. Data protection, privacy, and adherence to applicable regulations are the foundation of Inmar service capabilities. Any and all patient information on drug packaging will be promptly destroyed.

VI. OUTREACH PROGRAM DESIGN Ordinance No. NS-517.91 § B11-542(f) Ordinance No. NS-517.91 § B11-547(a-e)

Inmar will execute a comprehensive and measurable public outreach strategy to drive awareness of the Stewardship Plan and maximize participation as required in § B11-547. In addition to preventative education, Inmar’s strategy is designed to ensure that where and how to return Unwanted Covered Drugs is widely understood by County Residents, pharmacists, Retail Pharmacies, health care facilities and providers, veterinarians, and veterinary hospitals.

Inmar has a unique set of core capabilities, specifically in consumer marketing and activation. Thus, in addition to traditional outreach methods (signage, written materials, etc.), Inmar will drive participation among covered entities with modern, high-impact tactics such as influencer

Inmar has a long history of serving both commercial and government clients with stringent compliance standards such as the protection of Protected Health Information (PHI) and HIPAA.


marketing and targeted Media. Additionally, Inmar will provide onsite support at local outreach events sponsored by employers in the County.

Pursuant to § B11-547(a) (1), the individual components of Inmar’s public outreach strategy are detailed below. Across all tactics, key messages will include, but not be limited to, the following:

• Promote safe storage of all drugs, wanted or unwanted, by residents in their homes• Discourage stockpiling and storage of Unwanted Covered Drugs in the home• Describe where and how to return Unwanted Covered Drugs• Discourage improper disposal of Covered Drugs (e.g., flushing or solid waste collection)• Identification of locations and collection events in the County as part of National

Consumer Drug Take-Back Events.

In accordance with Sec. B11-542 (f), Inmar will coordinate promotional activities with other approved Plan Owner(s). Inmar will coordinate to ensure that residents clearly understand the logistics, safety and educational components of the Program. Inmar will coordinate educational outreach with other Plan Owners to ensure consistent messaging regarding the location of kiosks; safe disposal of medication; statistics regarding the dangers of pharmaceutical waste in the waste-stream, drug abuse statistics and other program advocacy; means of envelope distribution and any other pertinent information related to the success of the program. Inmar will coordinate with other Plan Owners to execute the Digital Media outreach and Social Influencer outreach, while the other plan operator focuses on traditional print and television media. This coordination will include the fair and equitable division of resources and ensure consistent messaging among the types of educational outreach. Inmar suggests the Plan Owners form a trade association to ensure that there are no inefficiencies or distortions due to collaboration. A trade association protects against the types of illegal agreements that can distort competition.

Inmar’s LifeInCheck™ Consumer Drug Take-Back website will ensure that all interested parties can easily identify, understand, and access the collection services provided by Inmar and other Plan Operators. Coordination efforts will include providing a single website and toll-free telephone number to access information about collection services for all approved Stewardship Plans and include all existing kiosk locations in the County as a single repository.

i. Educational & Outreach MaterialsInmar will equip pharmacies, healthcare facilities, and other interested community partners witheasily-consumable educational and outreach materials for dissemination to covered entitiesupon request and at no charge.

These materials will:• Provide instruction on how to safely store Covered Drugs at home• Inform of the risks of disposing of Covered Drugs in inappropriate waste streams (e.g.,

solid waste collection, sewer, or septic systems)


• Outline how to participate in the Covered Drug take-back program for safe disposal ofCovered Drugs.

All materials will be easily understandable by covered entities with varying levels of English proficiency as well as be provided in Spanish, Japanese, Korean, Mandarin, Hindi, and Tagalog and will leverage explanatory graphics to aid in comprehension. Please see Appendix C for example materials.

ii. Authorized Collector Marketing SupportTo drive awareness and participation at a local level, Inmar will provide individual authorizedCollectors with a variety of marketing assets at no charge, including in-store signage, socialmedia content kits, press release templates, a radio ad script, and scripts for Pharmacy staff tolet County Residents know that they can safely dispose of their Unwanted Covered Drugs atthat location. Authorized Collectors will be able to request additional marketing materialsthrough the help desk.

Please see Appendix D for example materials.

iii. WebsiteInmar will provide a mobile-optimized website, appropriately translated into specified languages, which will publicize collection options and educate interested parties on proper disposal practices. Inmar will use enhanced search engine optimization to ensure easy location and access.

Specifically, the website will: • Leverage Inmar’s collaboration with Google Maps to allow interested parties to find the

nearest drop-off site or Mail-Back Distribution Site via an interactive map. The list oflocations will be updated monthly to ensure accuracy.

• Include a location list inclusive of all kiosks located in the County including thoseoperated by other Plan Operators.

• Allow interested parties to request prepaid mailers.• Clearly indicate what substances are and are not accepted. Graphics of unacceptable

substances are provided for additional clarity.• Include educational and outreach materials promoting safe storage of Covered Drugs• Feature links to LifeInCheck™ Consumer Drug Take-Back social media pages for more

useful content.

Retailers or pharmacies interested in participating in the Stewardship Plan will request information through the website. In addition, current authorized Collectors have access to resources for compliant kiosk management (including installation, tracking and shipping).


Please see Appendix D for images of the website interface and functionality.

iv. Toll-Free NumberInmar will operate a multi-lingual, (English, Spanish, Japanese, Korean, Mandarin, Hindi, and Tagalog), toll-free call center that interested parties can call to learn more about the Stewardship Plan, Take-Back Events, and best practices for disposal of Unwanted Covered Drugs. The call center is operated with live operators and will be staffed with a third party service to assist with live translation in the required languages. All operators are trained to assist an answer questions related to any and all questions related to the Stewardship Plan operation including but not limited to Authorized Collector kiosk support and service requests. County Residents will also be able to request information about the nearest drop-off site or Mail-Back Distribution Site, or request that a prepaid mailer is sent to them.

Callers with medical emergencies will be directed to call 911. Patients with medication-related questions will be directed to contact their healthcare provider(s).

v. Social Influencer MarketingInmar is able to execute robust, data-driven social influencer marketing programs that activate

shoppers and patients alike. On average, Inmar executes approximately 500 such programsannually.

Inmar has a curated network of more than 12,000 highly-vetted influencers who are experts atcreating authentic, compelling content that drives awareness and inspires program participationamong County Residents. Inmar utilizes sophisticated influencer selection, data-driven contentdistribution, and audience re-engagement tactics to ensure that content is hyper-relevant andthat the County Residents receiving the content are the ones most inclined to take action.

Content can focus on an array of topical themes, however, Inmar’s recommendation would beone, or a combination of, the following:

• Tips for safe storage of drugs in the home prior to disposal• Education about the implications of improper Covered Drug disposal• Promotion of the Stewardship Plan, including directions on where and how to participate

Inmar executed a social influencer marketing program promoting drug take-back in April of 2019 which yielded exceptional results (see Sub-Section 7 for more information on impact measurement and reporting). The campaign generated 11.4MM impressions, but, more importantly, the posts themselves were highly engaging. The average click-through-rate (CTR) was 4.5% (a historical CTR benchmark in this category is 1.5 - 2.0%) and users spent an average of one minute and eight seconds on each post. Both metrics suggest users found the content compelling and useful. ROI for social influencer marketing campaigns is measured in


terms of return on Total Media Value (the combined value of earned and paid media for the campaign). In this case, TMV return was favorable at 2.1x.

Please see Appendix D for sample social influencer content.

vi. Targeted MediaInmar’s expert paid media team actively monitors social influencer content for the highestperformers - looking beyond vanity metrics to focus on deeper measurements such as views andengagements. The most engaging content is promoted across social platforms as well as off-siteMedia to amplify the message around Covered Drug take-back to a targeted cohort of interestedparties.

Inmar will leverage our partnership with PlaceIQ (an independent data and technology companythat helps businesses leverage location-based insights to connect with and understandaudiences) to deliver proximity-based SMART ads to County Residents. SMART ads allow adunits to be delivered to County Residents that are physically near selected locations (e.g., near acollection kiosk). More specifically, any device that routinely passes through a three-mile radius ofa collection kiosk location can be served ads promoting the program on commonly used mobileapps like CNN and The Weather Channel, even NFL Fantasy Football. With PlaceIQ’saddressable audience of 90MM households and 190MM devices across the US, content deliverycan be easily scaled to drive program awareness and participation.

vii. Impact MeasurementInmar will provide a description of outreach initiatives in its annual report, but also aims to providemore frequent and actionable reporting on the impact of such initiatives.

With specific regard to social influencer marketing and targeted Media, Inmar’s measurementtools and philosophies provide transparency and quantifiability over vanity metrics and theoreticalexplanations.Reporting will include:

• Third-party-verified Content View & Engagement reporting• Engagement breakdown by social platform, including Time on Content• Social Content Ad™ (aka social media ad) performance data• Total Media Value (TMV) calculations• Thumbnail links to all influencer content, and performance metrics for individualinfluencer posts (including TMV for each post).

viii. Collection Kiosk SignageThe collection kiosks themselves will be readily-recognizable. The standard color for the kiosks is brightgreen for easy identification, and each kiosk is adorned with clear graphical instructions in English,


Spanish, Japanese, Korean, Mandarin, Hindi, and Tagalog. Please see Appendix B for an image of the collection kiosk and disposal instructions.

ix. Biennial SurveyInmar will conduct a biennial survey of Santa Clara County Residents as well as pharmacists,veterinarians, and health professionals who interact with patients on use of medicines after thefirst full year of operation of the Stewardship Plan. The aim of the survey questions will be tomeasure the percent awareness of the Stewardship Plan, assess to what extent drop-off sites andother collection methods are convenient and easy to use, and assess knowledge and attitudesabout risks of abuse, poisonings, and overdoses from prescription and non-prescription drugsused in the home.

Draft survey questions will be submitted to the Director for review and comment at least 30 daysprior to the initiation of the survey. Survey results and administration will adhere to therequirements specified by the Director per § B11-547. The privacy of all survey respondents shallbe maintained.

VII. PROGRAM GOALS Ordinance No. NS-517.91 § B11-542(g)

Inmar’s goals are outlined below with both tables. These goals are aimed at providing excellent services over the beginning and extended life of this proposal.

Table 1: Program Collection Goals

6 Months 12 Months

● Initiate program operation● Increase authorized Collector drop-off sites in

population centers and areas outside ofpopulation centers.

● Help achieve the convenience standardcollectively with the existing provider.

• Inmar’s goal is 100 kiosks placed collectivelyacross the County to provide equitable andreasonably convenient access to CountyResidents. If this goal cannot be met,underserved areas will be targeted for Mail-Back Distribution Sites or Take-Back Events.

● Provide and communicate system forPharmacies to request Mail-Back Serviceenvelopes.

Table 2: Program Promotion Goals

Complete 6 Months 12 Months 18 Months

● Website launch ● Website functionality ● Website functionality ● Website


● Interested partyeducationalmaterials

● Authorized Collectormarketing supportmaterials

updates ○ Mail-Back Service

envelope requests○ Educational

materialsuploaded

○ AuthorizedCollector kioskmaintenanceresources andrequests

○ Collector andMail-BackDistribution Sitelist updated(ongoing)

● Initiate socialinfluencer andtargeted mediaoutreach (1influencercampaign and 2promotedLifeInCheckTM

posts per month)

updates ○ Translation into

specifiedlanguages

○ Collection site andreturn envelopedistribution site listupdated (ongoing)

● Continue socialinfluencer andtargeted mediaoutreach (1influencercampaign and 2promotedLifeInCheckTM

posts per month)

functionality updates ○ Collector and

Mail-BackDistribution Siteupdated(ongoing)

● Continue socialinfluencer andtargeted mediaoutreach (1influencercampaign and 2promotedLifeInCheckTM

posts per month)

VIII. DRUG SEPARATION & RECYCLING Ordinance No. NS-517.91 § B11-542(h)

DEA § 1317.75(c) prohibits handling substances after they have been deposited into a collection kiosk. For this reason, Inmar is unable to recycle drug packaging or separate covered drugs from packings. Inmar can, however, execute educational programs, as outlined in Section VI, to encourage County Residents to separate Unwanted Covered Drugs from their packaging and recycle the packaging prior to disposal.

Even though regulations prevent us from recycling drug packaging, Inmar has an interest in reducing waste and improving our environment. Through our RX Returns and related business lines, Inmar has saved over 20,000 barrels of oil, recovered over 11,000 megawatts of clean energy, and powered over 900 homes in the past two years alone. We will continue to look for opportunities to expand our eco-friendly efforts in Santa Clara County.

IX. ANNUAL REPORTS Ordinance No. NS-517.91 § B11-548(a-c) Regulation § 8 (A)

Inmar will submit an Annual Report in accordance with NS-517.91 § B11-548 and the Regulation


§ 8 (A) which will be submitted within six months after the end of the first 12-month period of theStewardship Plan. It will also be submitted annually thereafter describing the plan’s activitiesduring the reporting period. The “reporting period” will be the 12 month period since theStewardship Plan’s approval for the first report and for all subsequent reports.The report will include:

i. Report Narrative with the following sections:a. An executive summary providing a brief overview of the Stewardship Plan,

proposals to improve the Stewardship Plan, challenged encountered duringthe reporting period, and how those challenges will be addressed in the nextreporting period;

b. A summary of the Stewardship Plan’s goals and the degree of success inmeeting those goals, including a summary of efforts to meet the goals, anydifficulties in meeting the goals, and if any goals have not been met, whatefforts will be made in the next reporting period;

c. Identification of proposed goals to be accomplished in the next reportingperiod and if the proposed goals different from the original Stewardship Plangoals along with an explanation of why the goals have changed;

d. A description and summary of the Promotion System and hot it has beenimplemented;

e. A clearly marked “Safety and Security Report” identifying any known securityor safety incidents at Drop-Off Sites, Take-Back Events and Mail-BackDistribution Sites, or during transportation or disposal of Unwanted CoveredDrugs.

ii. Report data with the following sections:a. Identification of any changes to a Plan Operators contact information or its list

of participating Producers;b. For each Drop-off Site; the total weight of Unwanted Covered Drugs collected,

the number of times Unwanted Drugs were picked up for transportation perlocation and the number of times a secure collection kiosk had to be lockedbecause it reached capacity before its scheduled pickup;

c. For each Take-Back Event; its time, date, and location; how and when it wasadvertised; the total weight of Unwanted Covered Drugs collected; whetherthe secure collection kiosk reached capacity before the end of the Take-BackEvent; and how the Unwanted Covered Drugs collected at the Take-BackEvent were handled prior to disposal;

d. The total weight of Unwanted Covered Drugs transported by each Transporterand disposed of by each Disposal facility;

e. Foer each Medium used in the Promotion System: Target Rating Points anddocumentation verifying that outreach described by the Promotion System didin fact take place.

The program's annual expenditures will be dependent on the final agreement between Santa


Clara County and Inmar.

A. Potential Collection Sites 27

B. Kiosk Signage 32

C. Training Materials 34

D. Promotion Materials 55

E. Applicable Permits and Licenses 62

27 © Inmar 2020 Inmar authorizes the posting of the plan dated May 23, 2020 in accordance with the California Public Records Act, as well as Section B11-543 of the County of Santa Clara Ordinance Code for the purposes of making it available to the public for review and comment. Any other use requires express written consent of Inmar

Appendix A: Potential Collection Sites

Store Name Store Address Store City Status

DBA: WALGREENS # 07088 303 2ND ST LOS ALTOS In Discussions

LUCKY PHARMACY #723 2175 GRANT RD LOS ALTOS In Discussions

SAFEWAY PHARMACY #2814 160 1ST STREET LOS ALTOS Agreed

RITE AID #5886 2310 HOMESTEAD RD STE A LOS ALTOS Notified

CAMINO PHARMACY 701 E. EL CAMINO REAL MOUNTAIN VIEW

Notified

CVS PHARMACY # 16113 555 SHOWERS DR MOUNTAIN VIEW

Notified

DBA: WALGREENS # 00689 121 E EL CAMINO REAL MOUNTAIN VIEW

Notified

DBA: WALGREENS #13948 1905 W. EL CAMINO REAL MOUNTAIN VIEW

Notified

EL CAMINO HOSPITAL OUTPATIENT PHARMACY

2500 GRANT ROAD MOUNTAIN VIEW

Notified

SAFEWAY PHARMACY #2948 645 SAN ANTONIO RD MOUNTAIN VIEW

Agreed

WAL-MART PHARMACY 10-2280 600 SHOWERS DR MOUNTAIN VIEW

Notified

DBA COSTCO PHARMACY #143 1000 N. RENGSTORFF AVENUE

MOUNTAIN VIEW

Notified

SAFEWAY PHARMACY #0705 570 N SHORELINE BLVD MOUNTAIN VIEW

Agreed

CVS PHARMACY # 17583 298 W MC KINLEY AVE SUNNYVALE Notified

DBA COSTCO PHARMACY #423 150 LAWRENCE STATION ROAD

SUNNYVALE Notified

LUCKY PHARMACY #780 484 NORTH MATHILDA SUNNYVALE In Discussions

DBA: WALGREENS # 03380 1306 S MARY AVE SUNNYVALE Notified

DBA: WALGREENS # 07080 105 E EL CAMINO REAL SUNNYVALE Notified

DBA: WALGREENS #09782 780 E EL CAMINO REAL SUNNYVALE Notified

SAFEWAY PHARMACY #1196 639 SOUTH BERNARDO AVE SUNNYVALE Agreed

SAFEWAY PHARMACY #1439 785 E. EL CAMINO REAL SUNNYVALE Agreed

SAFEWAY PHARMACY #2887 150 E. EL CAMINO REAL SUNNYVALE Agreed

COMMUNITY, A WALGREENS PHARMACY #21141

217 ALMA ST STE 200 PALO ALTO Notified

DBA: CVS/PHARMACY # 03935 855 EL CAMINO REAL PALO ALTO Notified


DBA: WALGREENS #13596 300 UNIVERSITY AVE PALO ALTO Notified

MEDICAL PLAZA PHARMACY 211 QUARRY ROAD PALO ALTO Notified

DBA: WALGREENS # 03344 4170 EL CAMINO REAL PALO ALTO Notified

DBA: WALGREENS # 06869 2605 MIDDLEFIELD ROAD PALO ALTO Notified

SAFEWAY PHARMACY #1682 2811 MIDDLEFIELD ROAD PALO ALTO Agreed

CAMDEN PHARMACY 3189 S. BASCOM AVE CAMPBELL Notified

DBA: WALGREENS # 02957 1660 WINCHESTER BLVD CAMPBELL Notified

DBA: WALGREENS # 06585 1570 W CAMPBELL AVE CAMPBELL Notified

SAFEWAY PHARMACY #1293 2341 SO. WINCHESTER BLVD CAMPBELL Agreed

SAFEWAY PHARMACY #3241 950 W HAMILTON AVE CAMPBELL Agreed

DBA CVS/PHARMACY #17687 19499 STEVENS CREEK BLVD CUPERTINO Notified

DBA: WALGREENS # 04416 20011 BOLLINGER ROAD CUPERTINO Notified

KML PHARMACY INC 1655 S DEANZA BLVD CUPERTINO Notified

RITE AID #5967 20572 HOMESTEAD ROAD CUPERTINO Notified

SAFEWAY PHARMACY #3251 20620 HOMESTEAD RD CUPERTINO Agreed

CVS PHARMACY # 16971 6705 CAMINO ARROYO GILROY Notified

DBA COSTCO PHARMACY #760 7251 CAMINO ARROYO GILROY Notified

DBA: WALGREENS #09516 770 1ST ST GILROY Notified

MEDICAL PAVILION PHARMACY 9460 N NAME UNO STE 100 GILROY Notified

WAL-MART PHARMACY 10-2002 7150 CAMINO ARROYO GILROY Notified

DBA: WALGREENS # 07326 423 N SANTA CRUZ AVE LOS GATOS Notified

PHARMACA INTEGRATIVE PHARMACY, INC.

54 N. SANTA CRUZ AVE. LOS GATOS Notified

DBA: WALGREENS # 02786 14100 BLOSSOM HILL ROAD LOS GATOS Notified

RITE AID #5972 15920 LOS GATOS BOULEVARD

LOS GATOS Notified

SAFEWAY PHARMACY #1245 15549 UNION AVE LOS GATOS Agreed

SAFEWAY PHARMACY #2815 470 N. SANTA CRUZ AVE. LOS GATOS Agreed

DBA: WALGREENS # 03671 342 W CALAVERAS BLVD MILPITAS Notified

DBA: WALGREENS # 05480 1833 N. MILPITAS BLVD. MILPITAS Notified

SAFEWAY PHARMACY #1879 555 E CALAVERAS BLVD MILPITAS Agreed

TRI-CITY PHARMACY 1132 CADILLAC CT MILPITAS Notified

WAL-MART PHARMACY 10-2119 301 RANCH DR MILPITAS Notified

CVS PHARMACY # 17327 1061 COCHRANE RD MORGAN HILL Notified


DBA: WALGREENS # 04516 745 E DUNNE AVE MORGAN HILL Notified

RITE AID #5975 16000 MONTEREY STREET MORGAN HILL Notified

SAFEWAY PHARMACY #1455 840 E. DUNNE AVE MORGAN HILL Agreed

SAFEWAY PHARMACY #1891 235 TENNANT STATION MORGAN HILL Agreedd

WAL-MART PHARMACY 10-5766 170 COCHRANE PLAZA MORGAN HILL Notified

CVS PHARMACY # 17658 2004 EL CAMINO REAL SANTA CLARA Notified

DBA COSTCO PHARMACY #129 1601 COLEMAN AVE SANTA CLARA Notified

DBA: CVS/PHARMACY # 09262 222 SARATOGA AVE SANTA CLARA Notified

DBA: CVS/PHARMACY # 09944 3081 STEVENS CREEK BLVD SANTA CLARA Notified

DBA: WALGREENS # 02612 200 N WINCHESTER BLVD SANTA CLARA Notified

DBA: WALGREENS #15246 2140 EL CAMINO REAL SANTA CLARA Notified

DBA: WALGREENS # 02740 3460 EL CAMINO REAL SANTA CLARA Notified

HAN'S PHARMACY 3423 EL CAMINO REAL SANTA CLARA Notified

KAISER PERMANENTE PHARMACY #414 710 LAWRENCE EXPRESSWAY 4TH FL

SANTA CLARA In Discussions

LUCKY PHARMACY #773 3705 EL CAMINO REAL SANTA CLARA Notified

RITE AID #5976 2620 EL CAMINO REAL SANTA CLARA Notified

SAFEWAY PHARMACY #1990 3970 RIVERMARK PLAZA SANTA CLARA Agreed

WALMART PHARMACY 10-3123 3255 MISSION COLLEGE BLVD SANTA CLARA Notified

CVS PHARMACY # 17176 533 COLEMAN AVE SAN JOSE Notified

FRIENDLY PHARMACY INC 485 LEWIS RD STE D SAN JOSE Notified

LION PHARMACY INC 2857 SENTER RD SUITE A SAN JOSE Notified

DBA COSTCO PHARMACY #148 2201 SENTER RD SAN JOSE Notified

DBA: WALGREENS # 04372 780 E SANTA CLARA STREET SAN JOSE Notified

DOWNTOWN PHARMACY INC 60 N 13TH ST STE A SAN JOSE Notified

MEGA DRUGS 696 E SANTA CLARA STREET SAN JOSE Notified

WALMART PHARMACY 10-4174 1450 MONTEREY RD. SAN JOSE Notified

DBA: WALGREENS # 05454 1661 MCKEE RD SAN JOSE Notified

DBA COSTCO PHARMACY #470 5301 ALMADEN EXPRESSWAY SAN JOSE Notified

DBA: WALGREENS # 03378 1376 KOOSER ROAD SAN JOSE Notified

DBA: WALGREENS #12548 1130 FOXWORTHY AVE. SAN JOSE Notified

SAFEWAY PHARMACY #0997 1663 BRANHAM LANE SAN JOSE Agreed

WAL-MART PHARMACY 10-5884 5095 ALMADEN EXPY SAN JOSE Notified

DBA COSTCO PHARMACY #1267 6898 RALEIGH ROAD SAN JOSE Notified


KAISER ONCOLOGY PHRMCY #638 270 INTERNATIONAL CIR, 1ST FLR

SAN JOSE In Discussions

LUCKY PHARMACY #759 129 BERNAL ROAD SAN JOSE In Discussions

RITE AID #5983 6215 SANTA TERESA BOULEVARD

SAN JOSE Notified

RITE AID #5984 6091 MERIDIAN AVENUE SAN JOSE Notified

SAFEWAY PHARMACY #0695 6477 ALMADEN RD SAN JOSE Agreed

CVS PHARMACY # 17314 3155 SILVER CREEK RD SAN JOSE Notified

DBA: WALGREENS # 01179 1795 E. CAPITOL EXP SAN JOSE Notified

LEXANN PHARMACY INC. 1569 LEXANN AVE STE 104 SAN JOSE Notified

LINDA RX PHARMACY 1569 LEXANN AVE STE 130 SAN JOSE Notified

RITE AID #5985 1029 EAST CAPITOL EXPRESSWAY

SAN JOSE Notified

TULLY MEDICAL CLINIC PHARMACY 1693 FLANIGAN DR SAN JOSE Notified

CVS PHARMACY # 17100 1750 STORY RD SAN JOSE Notified

DBA: WALGREENS # 02081 1760 STORY ROAD SAN JOSE Notified

NOWRX INC. 1310 TULLY RD STE 101 SAN JOSE Notified

PRESCRIPTION HEADQUARTERS INC 1340 TULLY ROAD SAN JOSE Notified

VIET TOWN PHARMACY 999 STORY RD UNIT 9024 SAN JOSE Notified

CVS PHARMACY # 17045 879 BLOSSOM HILL RD SAN JOSE Notified

CVS PHARMACY # 17588 5630 COTTLE RD SAN JOSE Notified

DBA: WALGREENS # 02739 440 BLOSSOM HILL SAN JOSE Notified

LUCKY PHARMACY #763 844 BLOSSOM HILL RD SAN JOSE In Discussions

SAFEWAY PHARMACY #2900 5760 COTTLE ROAD SAN JOSE Agreed

CVS PHARMACY # 16115 1811 HILLSDALE AVE SAN JOSE Notified

DBA: WALGREENS # 02384 2680 UNION AVE SAN JOSE Notified

LUCKY PHARMACY #757 2027 CAMDEN AVE SAN JOSE In Discussions

RITE AID #5987 3171 MERIDIAN AVENUE SAN JOSE Notified

STANFORD SOUTH BAY CANCER CENTER PHARMAC

2589 SAMARITAN DRIVE ROOM 4205

SAN JOSE Notified

CVS PHARMACY # 17355 2161 MONTEREY HWY SAN JOSE Notified

DBA: WALGREENS # 02265 1130 BIRD AVE SAN JOSE Notified

DBA: WALGREENS # 07079 1615 MERIDIAN AVE SAN JOSE Notified

RITE AID #5988 1550 HAMILTON AVENUE SAN JOSE Notified


SAFEWAY PHARMACY #1483 1530 HAMILTON AVENUE SAN JOSE Agreed

DBA: WALGREENS # 03754 1399 W SAN CARLOS SAN JOSE Notified

SAFEWAY PHARMACY #1476 1300 W SAN CARLOS ST SAN JOSE Agreed

LUCKY PHARMACY #233 3457 MCKEE RD SAN JOSE In Discussions

RITE AID #5992 1030 SOUTH WHITE ROAD SAN JOSE Notified

COMMUNITY, A WALGREENS PHARMACY #21193

1757 W SAN CARLOS ST. SAN JOSE Notified

RITE AID #5993 1333 SOUTH WINCHESTER BLVD

SAN JOSE Notified

SCVH&HS REFILL CTR PHARMACY 871 ENBORG COURT SAN JOSE Notified

CVS PHARMACY # 16763 1600 SARATOGA AVE., STE 601

SAN JOSE Notified

DBA: WALGREENS # 00840 1334 SARATOGA AVENUE SAN JOSE Notified

SAFEWAY PHARMACY #1465 5146 STEVENS CREEK BLVD SAN JOSE Agreed

WALMART PHARMACY 10-2486 4080 STEVENS CREEK BLVD. SAN JOSE Notified

COSTCO PHARMACY #1004 1709 AUTOMATION PARKWAY

SAN JOSE Notified

DBA: WALGREENS # 00900 2105 MORRILL AVENUE SAN JOSE Notified

DBA: WALGREENS # 00842 350 N CAPITOL AVE SAN JOSE Notified

CVS PHARMACY # 17582 95 HOLGER WAY SAN JOSE Notified WAL-MART PHARMACY 10-3023 4055 EVERGREEN VILLAGE

SQUARE SAN JOSE Notified

LUCKY PHARMACY #758 565 WEST CAPITOL EXPRESSWAY

SAN JOSE In Discussions

SAFEWAY PHARMACY #0316 179 BRANHAM LANE SAN JOSE Agreed SAFEWAY PHARMACY #4905 6100 HELLYER AVE SAN JOSE Agreed DBA: WALGREENS # 03445 2799 S WHITE RD SAN JOSE Notified SAFEWAY PHARMACY #3095 2980 E CAPITAL EXPRESSWAY SAN JOSE Agreed


Appendix B: Kiosk Signage


Appendix C: Training Material

Training material provided to authorize Collectors include:

1. FAQs2. Container Instructions3. Steps to Start Document4. Installation Reference Guide5. Serialization Tracker

All of the aforementioned documents are provided on the following pages.

© Inmar 2020 Inmar authorizes the posting of the plan dated May 23, 2020 in accordance with the California Public Records Act, as well as Section B11-543 of the County of Santa Clara Ordinance Code for the purposes of making it available to the public for review and comment. Any other use requires express written consent of Inmar

Note: Two pharmacy personnel are required to install, remove, store and transfer the corrugate

collection container.

Consumer Drug Take-Back Client Service Team ● [email protected]

(800) 350-0396 Option 6 ● Mon - Fri 8am-5pm EST

WHAT TO EXPECT AS A NEW INMAR

CONSUMER DRUG TAKE-BACK PROGRAM CLIENT

1. You will receive a “welcome” email from [email protected].

This email will include “Steps to Start,” a Consumer Drug Take-Back

Serialization Tracking Sheet and Receptacle Installation Instructions.

2. You will receive your CDTB receptacle and the collection

container supplies via separate shipments within 5-7 business days

after returning the Agreement. The collection container supplies

should allow you to operate your program for three months.

3. Be sure to install your receptacle in strict accordance with

instructions provided to help ensure you remain compliant with the

Secure and Responsible Drug Disposal Act.

4. Prepare and install the collection container according to

instructions provided. Track the serialized inner liner from receipt to

return on the Serialization Tracking Sheet.

5. Return collection container to Inmar. When we receive your

second returned container, we will send you another three-month

supply of collection containers, liners and zip ties.

FREQUENTLY ASKED QUESTIONS







Installation / Removal

Question Answer

1 How is the receptacle

installed?

The receptacle must be affixed to a wall or bolted to the

floor for compliance with the Responsible Disposal Act.

Inmar provides a printed guide for easy installation.

2 Where are the keys located for the receptacle?

The keys are located in the top bin of the receptacle.

Please note there are two sets of keys provided for each

lock. We suggest these duplicates be immediately

separated and each set stored in a safe place.

3 If I need replacement keys,

where is the lock number

located?

Each lock has a lock number printed on the outside of the

lock. When ordering replacement keys, you will need to

reference the receptacle PC number which is located on

the inside left of the drop-door.

4 When should I ship

the collection container

to Inmar?

Full containers should be shipped immediately after the

inner liner is sealed and packaged for shipping. The

container is sent to you already prepared with a prepaid

FedEx shipping label.

5 How will I know when the

collection container is full?

The drop-door has an extended tongue that lowers down

into the container when the drop-door is closed. When the

product builds to a certain height, the door will have some

resistance in operation. This will indicate it is time to

change the container.

6 Where is the serial number

located?

The inner liner is serialized and the outside of the

cardboard shipping container is serialized. These serial

numbers match and are packaged as a kit. Therefore, it is

critical that the pieces of the kit stay together throughout

usage and return shipping.

Installation / Removal Continued






Question Answer

7

Do I need to wait until the

shipping company is on-site

for pickup before I change

the container?

As the pickup is standard FedEx, most of our customers

change the container and then call FedEx. Please be aware

that the DEA requires that the sealed container be held in

the controlled substances area during the time between

liner removal and pickup.

8

When ordering multiple

receptacles, is it required

that each receptacle be

shipped to the location

where they will be installed

or can they be shipped to a

central location and then

transported?

The metal receptacles can be shipped to whatever location

you choose. The supplies are shipped separately from our

facility in Fort Worth, TX. It will be important to notify your

staff to be on the lookout for these supplies so they are not

inadvertently discarded.

9 How do I order more

collection containers?

Upon receipt of your second returned container, Inmar will

automatically send you a supply kit for your next three

returns. If you need additional supplies, please contact

Inmar via the email address or phone number listed below.

Compliance / Regulatory

Question Answer

10

Is there a statement from

the DEA allowing for video

monitoring of the

receptacle?

There is no statement allowing video surveillance.

However, the regulations state that regular monitoring by

employees is required. This is the exact text from the

Regulation Part 1317 Subpart B (1317.75 2(i)): ”(i) At a

hospital/clinic: A collection receptacle shall be located in an

area regularly monitored by employees, and shall not be

located in the proximity of any area where emergency or

urgent care is provided.” VIDEO MONITORING IS NOT

ALLOWED IN CALIFORNIA (not part of DEA regulation).

11 Are the items collected

considered medical waste?

Household pharmaceuticals collected by take-back

programs are not considered medical waste and, therefore,

not subject to EPA RCRA rules. The items collected are

considered household waste as long as the take-back

program rules are followed. That is, no sharps, non-

pharmaceuticals, etc. allowed in the receptacles.

Compliance / Regulatory Continued






Question Answer

12

What should the pharmacist

do if they see someone put a

“not allowed” substance or

item in the receptacle?

Those responsible for monitoring the receptacle should do

their best to keep this from occurring. However, the DEA

specifies opening the inner liner is not allowed.

13

Can non-controlled

medications and controlled

substances be placed in

the LifeInCheck Consumer

Drug Take-Back receptacle?

Yes. Comingling of controlled and non-controlled substances

is allowed in the take-back receptacle.

14

If a patient asks the

pharmacist to place their

medications in the

receptacle, can they do so?

With an exception for personnel in a long term care facility,

the drug owner or a member of his/her household are the

only persons allowed to place items in the take-back

receptacle.

15 Where can I find information

on DEA regulations?

You can access links for DEA registrants, LTCFs and more

here: https://www.deadiversion.usdoj.gov/drug_disposal/index.html.

16 Are there any regulations

limiting the number of keys I

can replicate for these units?

The DEA does not specify anything regarding the keys, only

that the receptacle is secure, monitored and that two staff

members are present when it is opened.

Marketing / Promotion

Question Answer

17 Can the pharmacy add a

logo to, or brand, the

receptacle?

The magnet provided by Inmar must be placed on the front

door of the receptacle. The sides can be used for your

logo/brand. If the full-price subscription was purchased, then

the pharmacy can place a logo/brand on the sides or front.

18

Are there marketing

materials available to help

me promote my take-back

program?

Please contact Inmar for the latest marketing materials.

These include signage, social media copy and images as

well as language for press releases and ads.


https://www.deadiversion.usdoj.gov/drug_disposal/index.html

COLLECTION CONTAINER VISUAL INSTRUCTIONS

CALIFORNIA GUIDELINES

CONSTRUCTION, INSTALLATION, REMOVAL AND SHIPPING OF COLLECTION CONTAINER

Questions: Contact Consumer Drug Take–Back Client Service Team

[email protected]

1–800–350–0396 Option 6, Mon–Fri 8am-5pm EST


KIT CONTENTSEach shipment contains 3 individually packaged kits with unique components to each kit.

DO NOT rearrange contents between kits.

IMPORTANT:For every shipment – serial number on inner liner & serial number on cardboard

1 The kit will arrive in a package similar to this.

1 Zip tie

3 Inner liner

2 The kit will include three numbered and pre-labeled boxes.

2 Absorption pad

4 Numbered and pre-labeled box

THE KIT:

Each kit contains one of each of the following items:

©2020 Inmar Inc. All Rights Reserved 2

container MUST MATCH.© Inmar 2020 Inmar authorizes the posting of the plan dated May 23, 2020 in accordance with the California Public Records Act, as well as Section B11-543 of the County of Santa Clara Ordinance Code for the purposes of making it available to the public for review and comment. Any other use requires express written consent of Inmar

KAlstad

Sticky Note

Completed set by KAlstad

NOTE: All direct contact with the LifeInCheck Consumer Drug Take-Back Container should

be performed by two pharmacy personnel.

1 Document the serial number and receipt

of each inner liner on the Drug Disposal

Serialization Tracking Sheet.

2 Close and tape the box bottom. Seal the middle

seam and both outside seams. Leave no un-taped

spaces along the seams. We recommend 1 strip

of tape across the bottom seam, 2 strips of tape

over the edge seams and 2 strips of tape across

the bottom of the container placed diagonally.

See illustration to right.

3 Place inner liner into the

box and fold

excess

material at top

over box flaps.

KIT INSTRUCTIONS– INSTALLING A NEW COLLECTION CONTAINER

X TAPING METHODH TAPING METHOD

BOTTOM OF THE BOX



5 Place absorbent pad into the installed inner liner.

6 Install the lined box (now the

“Container”) into the Collection Kiosk.

4 Tape the zip tie to the inside of the door

for later use.

KIT INSTRUCTIONS– INSTALLING A NEW COLLECTION CONTAINER



8 Lock the bottom door and unlock the drop

door at the top of the receptacle to begin

drug disposal collection.

9 Store remaining spare kits securely

for future use.

10 Use the Drug Disposal Serialization Tracking Sheet

to document all inner liner events.

KIT INSTRUCTIONS– INSTALLING A NEW COLLECTION CONTAINER7 Immediately document installation of Container

on the Drug Disposal Serialization Tracking Sheet.



NOTE: All direct contact with the LifeInCheck Consumer Drug Take-Back Container

should be performed by two pharmacy personnel.

1 Unlock and open bottom door.

2 Remove full Container from Collection Kiosk DO

NOT sort, count or inventory pharmaceuticals or

touch contents of inner liner prior to sealing.

KIT INSTRUCTIONS– REMOVING AND SEALING A FULL COLLECTION CONTAINER Note: The total weight of the Container ready for shipping may not exceed 66 pounds.



osalamac

Highlight

osalamac

Sticky Note

redundant - should be removed

KIT INSTRUCTIONS– REMOVING AND SEALING A FULL COLLECTION CONTAINER

4

5

Bend the gathered portion at the halfway point

and fold the top half alongside the bottom half.

Repeat Step 4 - Again bend the gathered portion

at the halfway point and fold the top half alongside

the bottom half.

3 Immediately seal the Inner Liner by gathering

the top of the Liner.




7 Close and tape the box top. Seal the middle seam

and both outside seams. Leave no untaped spaces

along the seams. We recommend 1 strip of tape

across the top seam, 2 strips of tape over the edge

seams, and 2 strips of tape across the top of the

Container placed diagonally. See illustration to

right.

6 Cinch and fully tighten the provided zip tie around

both halves of the gathered portion of the liner to

secure the top.


TOP OF THE BOX



osalamac

Sticky Note

Unmarked set by osalamac


8

9

Document removal of Container on the Drug

Disposal Serialization Tracking Sheet.

Store the sealed Container in a secure location

until shipped. The Container is pre-labeled for

shipping. Document the shipping of the Container

on the Drug Disposal Serialization Tracking Sheet.



PLEASE NOTE:

Your cardboard container is pre-labeled for shipping. This

label is pre-paid with FedEx and must not be copied.

Additional charges may apply for non-compliance.

Questions: Contact Consumer Drug Take–Back Client Service Team

[email protected]

1–800–350–0396 Option 6, Mon–Fri 8am-5pm EST


RECEPTACLEYou will receive your Consumer Drug Take-Back receptacle and your supplies in separate shipments. After unpacking the Consumer Drug Take-Back receptacle, it must be installed according to the “Responsible Disposal Act” Rule which means it must be connected to a wall or the floor ensuring the receptacle is secure. Your receptacle will come pre-drilled in the bottom to make installation easier. Please see the installation instructions included in this email.

Your usage of the Inmar Consumer Drug Take-Back Program indicates your agreement to accept responsibility for following the Federal Guidelines. DEA’s Final Rule, which implements the Secure and Responsible Drug Disposal Act of 2010 (“the Disposal Act”).

CONSTRUCTING YOUR INNER CONTAINERConstruct 1 cardboard container applying an appropriate amount of tape to the bottom to ensure safe transportation. Seal the middle seam and both outside seams. Leave no untaped spaces along the seams and no less than 3 inches of tape overhang on each side. We recommend 2 strips of tape across the bottom seam and 2 strips of tape over the edge seams and 2 strips of tape across the bottom of the container placed diagonally. See illustration to right.


CONSUMER DRUG TAKE-BACK

GETTING STARTED

inmar.com • (866) 440-6917 • [email protected] © 2020 Inmar, Inc. All Rights Reserved. RX-B-16 122019

SUPPLIESAfter completing the proper installation of your Consumer Drug Take-Back receptacle, you should unpack your supplies.

Included are supplies to operate your Consumer Drug Take-Back program for 3 shipments. Upon Inmar’s receipt of your second container (return) shipment, we will automatically send your next 3 shipment supply package so you will always have the necessary supplies on hand. Staged shipping of your supplies alleviates your need to store large supply quantities.

Each shipment contains 3 individually-packaged kits with unique components to each kit. DO NOT rearrange contents between kits.

Each kit contains one of each of the following:

• Serialized Inner Liner• Absorption pad• Serialization Tracking Sheet

(emailed separately)

• Black Zip Tie • Set of instructions (Single Page)• Numbered and pre-labeled

cardboard box

It is important for you to document receipt of the serialized Inner Liners on your tracking form. To assist, Inmar has provided the Serialization Tracking sheet (Inner Liner Tracking Form). Maintain a copy of the completed Serialization Tracking Sheet in your files for at least 2 years (at the collector’s registered location). Refer to 21 CFR § 1304.04(a).

NOTE: All direct contact with the unsealed Consumer Drug Take-Back liner must be performed by two pharmacy personnel.



inmar.com • (866) 440-6917 • [email protected]© 2020 Inmar, Inc. All Rights Reserved. RX-B-16 122019


1. Place Serialized Inner Liner into the box and fold excessmaterial at top over box flaps. Leave Black Zip Tie tapedto the Liner for later use. (When inserting Inner Liner, check to ensure Serial Number on Serialized Inner Linermatches Serial Number on the shipping container.)

2. Place absorbent pad into the installed Liner.

3. Install the lined box (now the “Container”) into theCollection Receptacle.

4. Immediately document installation of Container(column 3 of the Serialization Tracking Sheet).

5. Store remaining spare kits securely for future use.

6. Lock bottom door and unlock top door to begin CDTBcollection.

PREPARING YOUR CONTAINER FOR USAGE

Note: Container is pre-labeled and ready to return. The marking requirements of 49 CFR 172.301(c) do not apply. The container shall not contain any markings to indicate that the contents contain controlled substances.

1. Ship in accordance with the DOT Special Permit.Container comes pre-paid and pre-labeled for shipping.

2. When the Liner is shipped, complete column 5 on theSerialization Tracking Sheet. The completed Serialization

Tracking Sheet is a record of Liner Events and should be filed in accordance with DEA guidelines.

3. Maintain a copy of the completed Serialization TrackingSheet in your files for at least 2 years (at the collector’sregistered location). Refer to 21 CFR § 1304.04(a).

4. Inmar will maintain your modified Form 41 notingdestruction date and time on file and will provide itto you upon request.

SHIPPING AND RECORD KEEPING

Note: The total weight of the Container ready for shipping MAY NOT EXCEED 66 POUNDS IN WEIGHT.

1. Unlock and open bottom door.

2. Remove full Container from Collection Receptacle. DO NOT sort, count or inventory pharmaceuticalsor touch contents of Liner prior to sealing.

3. Immediately seal the Serialized Inner Liner by gatheringthe top of the Liner, bending the gathered portion atthe halfway point and folding the top half alongside thebottom half. For extra security, bend the gathered portionat the halfway point a 2nd time. While folding Liner, keepSerial Number on Liner visible. Securely cinch theprovided Black Zip Tie around both halves of the gatheredportion of the Liner to secure the top. Ensure that the ziptie is completely above the exposed end of the top half of

the gathered portion and that the zip tie is fully tightened This will provide an airtight seal at the open end of the Liner to prevent leakage of any trace liquids that may be inside.

4. Close and tape the box top. Seal the middle seam andboth outside seams. Leave no untaped spaces along theseams and no less than 3 inches of tape overhang on eachside. We recommend 2 strips of tape across the top seamand 2 strips of tape over the edge seams and 2 strips oftape across the top of the container placed diagonally. See illustration of taping method above.

5. Document removal of Container(in column 4 of Serialization Tracking Sheet).

6. Store the sealed Container in a secure locationuntil shipped.

PREPARING YOUR CONTAINER FOR SHIPPING


TO START TO CLOSE

QUICK STEPS


VISIT INMAR.COM OR CALL US AT (866) 440-6917 FOR MORE INFORMATION

© 2020 Inmar Inc. All Rights Reserved. RX-B-16 122019

01 Install the Consumer Drug Take-Back Receptacle per DEA guidelines.

02 Properly tape container at bottom.

03

Place Serialized Inner Liner inside with top folded over container flaps. (When inserting Serialized Inner Liner, check to ensure Serial Number on Inner Liner matches Serial Number on the shipping container.)

04 Place absorbent pad in bottom of Serialized Inner Liner.

05 Document the installation of the container on the Serialization Tracking Sheet.

06 Install container inside Consumer Drug Take-Back receptacle.

07 Lock bottom door and unlock top door to begin drug take-back collection.

01 Open bottom door.

02 Remove full container, total weight of container may not exceed 66lbs in weight.

03 Ensure the Serial Number is visible before using a zip tie to secure Serialized Inner Liner bag top.

04 Document the removal of the container on the Serialization Tracking Sheet.

05 Properly tape container at top.

06 Container is pre-labeled for return shipment.



SERIAL NUMBER

Date Liner Acquired(1 Signature)

Date Liner Installed (2 Names & Signatures)

Date Removed (2 Names & Signatures)

Date Transferred to Storage (2 Names & Signatures)

Date Shipped (2 Names & Signatures)

Ex: 32587 4/26/19

4/26/19 5/26/19 5/26/19 5/27/19

John Jones John Jones John Jones John Jones John Jones John Jones John Jones John Jones

John Jones Sally Smith Sally Smith Sally Smith Sally Smith Sally Smith Sally Smith Sally Smith Sally Smith

DRUG DISPOSAL SERIALIZATION TRACKING SHEET INNER LINER TRACKING FORMM

Instructions: Each Inner Liner (container) will bear a permanent, unique identification number to enable tracking on the Inner Liner form. Columns 1 and 2 are to be completed upon receipt of Inner Liner. Column 3 is to be completed upon installation of the container into the collection receptacle. Column 4 is to be completed upon removal of the container from the collection receptacle. Column 5 is the be completed if the Inner Liner is removed from the receptacle and placed in storage before being shipped. Column 6 should be completed when the inner liner is shipped for destruction. Maintain a copy of the completed “Inner Liner form” and other records, as applicable, on file at the collector’s registered location for at least 2 years.

The purpose of this form is to document the use of the Inner Liner throughout a collection event. Although proper use of this form is intended to help the collector meet record keeping requirements, requirements may vary based on the registrant location. It is the responsibility of each registered collector to understand and comply with all federal, state and local regulatory requirements pertaining to take-back pharmaceuticals applicable at the collector’s registered location. The Inner Liner form is not a DEA Form 41. © 2020 Inmar Intelligence, Inc. All Rights Reserved. RX-SS-37 032320

Name of Collecting Pharmacy Address of Collecting Pharmacy Collecting Pharmacy DEA #:

Size of Liner Address of Reverse Distributor/Disposal Site Reverse Distributor/Disposal Site DEA #

1 2 3 4 5 6

Serialization Tracking Sheet should be validated by 2 pharmacy employees.

DRUG DISPOSAL SERIALIZATION TRACKING SHEET INNER LINER TRACKING FORMM

© Inmar 2020 Inmar authorizes the posting of the plan dated May 23, 2020 in accordance with the California Public Records Act, as well as Section other use B11-543 of the County of Santa Clara Ordinance Code for the purposes of making it available to the public for review and comment. Any

requires express written consent of Inmar

RDDROCERSNOISIVERMYSETAD AUTH CK

07/18/2017 A RELEASEDFOR PRODUCTION KQWM

ANCHOR FOR CONCRETE FLOORSCREW FOR

WOOD FLOOR

Use four clearance holes in bottom for securing cabinet to � oor.

INSTALLATION

STEP 1: PLACE CABINET IN PERMANENT LOCATION

STEP 2: USING THE CABINET BASE AS A TEMPLATE, MARK FLOOR USING CLEARANCE HOLES AS SHOWN IN FIGURE 1

STEP 3: DRILL HOLES FOR FLOOR SUBSTRATE

INSTALLATION INSTRUCTIONS

FIGURE 1© Inmar 2020 Inmar authorizes the posting of the plan dated May 23, 2020 in accordance with the California Public Records Act, as well as Section B11-543 of the County of Santa Clara Ordinance Code for the purposes of making it available to the public for review and comment. Any other use requires express written consent of Inmar

55© Inmar 2020 Inmar authorizes the posting of the plan dated May 23, 2020 in accordance with the California Public Records Act, as well as Section B11-543 of the County of Santa Clara Ordinance Code for the purposes of making it available to the public for review and comment. Any other use requires express written consent of Inmar

Appendix D: Promotion Material

1. Sample Education Materials


2. Sample Authorized Collector Marketing Support


3. Website Interface and Functionality


4. Sample Social Influencer Content


Appendix E: Applicable Permits and Licenses

Tracking Number: 2019085496 DUNS Number on file: 613608574

East Building, PHH-30

U.S. Department 1200 New Jersey Avenue S.E.

of Transportation Washington, D.C. 20590

Pipeline and Hazardous

Materials Safety Administration

SPECIAL PERMIT AUTHORIZATION

DOT-SP 20255

EXPIRATION DATE: 2021-07-31

GRANTEE: INMAR RX SOLUTIONS, INC.

FORT WORTH, TX

In response to your August 12, 2019 application for party status

to DOT-SP 20255 and additional information dated August 22, 2019,

INMAR RX SOLUTIONS, INC. is hereby granted party status to DOT-SP

20255 as a shipper only in accordance with 49 CFR 107.107.

Copies of this special permit may be obtained by accessing the

Office of Hazardous Materials Safety Homepage at

http://www.phmsa.dot.gov/hazmat/regs/sp-a/special-permits/search.

The most recent revision of the special permit supersedes all

previous revisions of the special permit. Photo reproductions and

legible reductions of this special permit are permitted. Any

alteration of this special permit is prohibited.

If you have questions regarding this action please call the

Office of Hazardous Materials Safety, Approvals and Permits

Division at (202)366-4535.

Issued in Washington D.C. on September 04, 2019.

___________________________

for William Schoonover

Associate Administrator for Hazardous Materials Safety

Enforcement Action Summary Report

Facility Aragonite

Date

Recieved

Agency Alleged Violation Proposed

Penalty

Status Resolution

Date

Penalty PaidEnforcement Type

10/20/2016 UDEQ 1) Storage facility for water supply had a leak atthe time of inspection, 2) the public water supplystorage vessel showed signs of a leak.

$0.00 Resolved w/o Penalty

12/14/2016 $0.00Notice of Violation

Description of Resolution: Repaired the tanks.EA Number:

2/8/2017 UDEQ - DDW Failure to monitor and report for pesticides and volatile organic compounds in 2016.

$0.00 Resolved w/o Penalty

2/15/2017 $0.00Notice of Violation

Description of Resolution: Updated testing was conducted.EA Number:

5/16/2018 UDEQ - Division of Air Quality

Failure to submit stack test results, deviation reports, leak detection and repair reports, Benzene NESHAP reports, semi-annual reports and compliance certifications in a timely manner.

$23,750.00 Resolved 5/21/2018 $23,750.00Notice of Violation

Description of Resolution:EA Number:

Tuesday, August 6, 2019 Page 1 of 2

1/28/2019 US DEA 1) Failure to file annual inventory, 2) delinquentfiling of quarterly ARCOS reports, failure tomaintain a separate file for Schedule 1 and 2 andSchedule 3 through five controlled substances,4) failure to record time of annual inventory.

$120,000.00 Resolved 5/8/2019 $96,000.00Notice of Violation

Description of Resolution: Payment of a civil penalty.EA Number:

Tuesday, August 6, 2019 Page 2 of 2

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